ML20151T933
| ML20151T933 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/09/1988 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| References | |
| NUDOCS 8808180335 | |
| Download: ML20151T933 (2) | |
See also: IR 05000293/1988016
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.AUGM91988
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Docket No. 50-293
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Boston Edison Company
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ATTN: Mr. Ralph G. Bird
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Sonir.e Vice President - Nuclear
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800 Boylston Street
Boston, Ma w.husetts 0?l99.
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Gentlemen:
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Subject:
Inspection No. 50-293/88 .17 and .*ianagement Meeting 50-293/88-26'
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Tnis refers to your letter dated June 25, 1988, in response to our letter
dated May 25, 1988 concerning inspection 50-293/83-17; and to your letter
dated July 7, 1988 which was in response to additional concerns raised at our
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Management P.eeting 50-293/88-26 condiacted. on Juna 27, 1988 and in a subsequent
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phone conversation between Mr. Galla of this office end Mr. K. Highfi D of -your
staff on July 1,1983.
Thank you for informing us of the corrective ~and provar;tive actiona documeritd
in your letters. These actions will be examined during a future inspect!_on of
ycur licensed program.
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Your cooneration with us is appreciated.
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Sincerely,
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ORl0lNAL SIGNED SY
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WILLIAM V. JOHNSTON
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William V. Johnston, Act %g Director
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Division of Reactor Safety
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0FFICIAL RECORD COPY
RL PILGRIM 88-17 - 0001.0.0'
08/04/88
8808180335 880809
ADOCK 05000293
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Boston Edison Company
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cc:
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K. Highfill, Station Director
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R. Anderson, Plant Manager
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J. Keyes, Licensing Division Manager
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E. Robinson, Nuclear Information Manager.
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R. Swanson, Nuclear Engineering Department Manager
The Honorable Edward J. Markey
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The Honorable Edward P. Kirby
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The Honorable Peter V.'Forman
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B. McIntyre, Chairman, Department of Public Utilities
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Chairman, Plymouth Board of Selectmen
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Chairman, Outbury Board of Selectmen
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Plymouth Civil Defense Director
P. Agnes, Assistant Secretary of Public Safety, Commonwealth of
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S. Pollard, Massachusetts Secretary of Energy Resources
R. Shimshak, MASSPIRG
PublicOccumentRoom(POR)
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Local Public Document Room (LPOR)
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Nuclear Safety Information Center (NSIC)
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"RC Resident Inspector
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Commonwealth of Massachusetts (2)
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Region I Docket Room (with concurrences)
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R.Blough,DRP
L. Doerflein, DRP
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R. 3orer. DRSS
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0FFICJAL RECOR9 t@Y
RL PILGU M 88-17 - 0002.0.0
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8057tW ED60N
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Ngnm Nucidar Pour station
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Rocky Hill Road
Ptyrnoutn. Yassachusetts 0236o
June 25, 1988
le'Pr
o W. M-M
ident - Nuclear
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mashington, D.C. 20555
Dockei No. 50-293
Licento No. DPR-35
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Subject:
NRC Insoectiop_Agpprt 50-293/88-17 (Rescortt).
Dear Sir:
Attached is Boston Edison Comp &ny's response to the NRC Region I Maintenance
Assessment Team Inspection conducted from April 25 through May 5, 1988, at the
Pilgrim Nuclear Power Station (9NPS), Plymouth, Massachusetts and at the
Braintree, Massachusetts engineering office.
Boston Edison Company concurs with the NRC Assessment Team conclusions that:
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No violations of regulatory requirements were identified during the
inspection.
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Several progra'.a and performance strengths werc identified.
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Certain concerns, including some that were considered significant,
were identified.
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These conclusions are consistent with the actions mandated by our Material
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Condition Improvement Action Plan (MCIAP) and the independent conclusions of
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our Restart Readiness Self-Assessment (RRSA) conducted between April 18, 1980
and May 2, 1988.
Boston Edison Company has accelerated the actions necessary
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to implement those MCIAP and RRSA ite:ns which will resolve the significant NRC
Assessment Team concerns.
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Boston Edison Company will address prior to restart, concerns identified in
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the areas of (1) maintenance program, (2) staffing, and (3) program
performance. The details and status of our corrective actions are discussed
in Attachment A.
R. I.edgett and R. Blough agreed on 6/23/88 that sul;mittal of
this letter by 6/27/88 is acceptable.
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Bost6n Edison Company
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Docket No. 50-293
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License No, DPR-35
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Please do not hesitate to contact me if there are questions or comments
regarding the attached response.
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RLC/b1
Attachment
cc: Mr. Hilliam Russell
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Regional Administrator, Region I
U.S. Nuclear Regulatory Comission
475 Allendale Rd.
King of Prussia, PA 19406
Sr. Resident Inspector - Pilgrim Station
Standard BECo Distribution
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ATTACHMENT
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Boston Edison Company
BECo Ltr: 88-98
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Pilgrim Nuclear Power Station
Docket No. 50-293
License No. DPR-35
Insoection Reoort 88-17 ResRQa51
Boston Edison has reviewed the concerns discussed in Section 1.2 of the NRC
Maintenance Assessment Team Report and concurs with the NRC Assessment Team
conclusions. These conclusions are consistent with the independent actions
and conclusions of our Material Condition Improvement Action Plan (HCIAP) and
our Restart Readiness Self-Assessment (RRSA) conducted during the period of
April 18, 1988 to May 2, 1988.
Boston Edison has accelerated the
implementation of those MCIAP and RRSA actions necessary to resolve the
significant NRC Assessment Team concerns. The areas of concern are:
Maintenance Program
Maintenance Staffing
Program Performance
I.
Maintenance Program
The following is a summary of the actions taken in the area of the Maintenance
Program:
Boston Edison has taken action to more clearly define work control
practices in approved plant and department procedures as well as to
formalize the current plant work control practices for Maintenance.
To accomplish this, the ongoing comprehensive rewrite of the PNPS
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Maintenance Section Manual was completed to more clearly describe its
purpose, intent, structure, and its relationship to other station
directives and procedures.
This rewrite incorporates INPO Guidelines85-038, "Conduct of Maintenance at Nuclear Power Station", to enhance
maintenance practices at Pilgrim Station. Additicnally, Boston
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Edison performed a major rewrite of PNPS Procedure 1.5.3,
"Maintenance Recuests", to incorporate improved administrative
controls. A new procedure, PNPS Procedure 1.5.3.1, "Haintenance Work
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Plan", was developed to be utilized in conjunction with the
Haintenance Request (HR) as an administrative tool to provide a Hork
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Plan which further defines (details) the maintenance activity to be
performed.
Boston Edison has taken action to provide improved specifications for
unique and routine maintenance previously covered by Procedure 3.H.1-il,
"Routine Maintenance", to ensure adequate preparation of work packages for
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such tasks.
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ATTACHMENT 'A'
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Insoection Renort 88-17. Response
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To accomplish this Boston Edison prepared, approved, and implemented
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Procedure 1.5.3.1, "Maintenance Mork Plan".
This procedure, used in
conjunction with the revisto Procedure 1.5.3, "Maintenance Requests",
provides an effective means to specify unique instructions for
routine maintenance tasks formerly covered by Procedure 3.M.1-11.
Maintenance Mork Plans are now required to contain specifically
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defined steps for the performance and documentation of maintenance
activities.
MRs written prior to the implementation of the revised
maintenance program, and which referenced Procedure 3.M.1-11, are
reviewed and approved by the Plant Maintenance Section Manager prior
to implementation to ensure that the intent of the revised
maintenance procedures is met.
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II. Maintenance Staffina
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Bosten Edison conducted a review in the last quarter of 1987 of the authorized
staffing level. An integral part of this review included an estimate of
manpower resources required to meet and maintain the established performance
goals of the Maintenance Section.
Based on this review, the permanent full-time Maintenance complement has been
increased.
Ten of these positions are supervisory positions.
Revisedjob
descriptions have been developed for this expanded organization and hiring
efforts are aggressively underway.
Attention to the plant's material condition has been increased by the
expansion of the permanent complement of niaintenan:e personnel. Attention has
been further enhanc.ed, by assignment of the Systems Engineering Division (SED)
to provide increased support to individual maintenance activities thereby
reducing the burden on maintenance personnel.
The SED conducts in-depth
research for the majority of individual Failure and Halfunction Reports
(F&MRs).
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The overall knowledge, experience, and performance levels of the Maintenance
staff is being improved. This is being accomplished by:
Recruitment of personnel with greater experience levels to fill
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vacant and new positions.
Improved training.
Development of well-defined job descriptior.s.
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Improved Maintenance management and supervision.
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The experience level of the Maintenanc.e staff has been further enhanced by
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creating the position of Deputy to the Maintenance Section Manager.
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I,osition has been filled by an individual with approximately 25 years of
experience in production and planning for nuclear repair, overhaul, and
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refueling work.
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ATTACHMENT 'A'
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Insoection Recort 88-17 Resoonse
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III. Maintenance Performance
Boston Edison, through programmatic changes, is implementing actions which
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will increase attention to detail as well as improve familiarity with various
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elements of the werk co'ntrol process.
The improvement in the mainteaance
program described in Section I above, in conjunction with the staffing
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increase and upgrades, is designed to result in improved maintenance
performance.
The following is a summary of the actions taken to improve performance:
Boston Edison has taken action to ensure that hrs are both complete and
correct.
The revision of Procedure 1.5.3 incorporated additional guidance and
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requirements regarding the preparation, review, and approval of hrs
to ensure correctness and completeness.
The Haintenance Summary
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Control (MSC) form has been deleted.
The function of the MSC has
been integrated into the new Maintenance Work Plan (Procedure
1.5.3.1).
Training has been conducted, with emphasis on the
appropriate method of processing a work plan and the need for the
documentation to be complete and accurate.
Boston Edison has taken action to control expansior or revision of the
original work scope during maintenance in the field and to require
documentation of the actual work performed.
To accomplish this, Procedure 1.5.3.1 specifies the controls
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necessary to make revisions to the work package. Additionally, any
revision to the Work Plan must be reviewed and approved in the same
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manner as the original document.
The work performed will be
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documented and will become a part of the completed maintenance
package.
Boston Edison has taken action to ensure that complete work packages,
including necessary instructions, are available at the work site.
The revised maintenance program now provides the necessary guidance
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and program controls to ensure that work packages, including the
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necessary instructions, are available at the applicable work site
when maintenance activities are being performed.
Boston Edison has taken action to ensure that Maintenance provides
documentation of material used, maintenance and test equipment
information, and work performed (including torque values).
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The Work Plan now requires this information to be documented by the
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maintenance personnel and becomes a part of the completed work
packa e.
The process develops a chronological history of the
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indiv dual activities.
Boston Edison has taken action to improve storage and retention of
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maintenance records.
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ATTACHMENT 'A'
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Insoection Reoort 88-17 Resstant
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Upon completion of a maintenance task, the final work package is
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returned to the responsible Staffing / Planning Engineer for review and
closure.
It is then processed by Document Control for retention as a
complete package.
Boston Edison has taken action to ensure proper documentation of post work
testing.
The Work Plan now requires the maintenance post work testing to be
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identified, reviewed for adequacy, and results documented as part of
the completed work package.
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These program improvements, coupled with the increased management focus and
direction, will ensure continued program improvement.
IV. 01erview of the Revised Maintenance Program
The comprehensive rewrite of the Maintenance Section Manual for PNPS is
complete. The changes and additions more clearly describe its purpose,
intent, structure, and its relationship to other station directives and
procedures. This rewrite incorporates INPO Guidelines85-038, Conduct of
M;intenance at Nuclear Power Stations, to enhance maintenance practices at
Pilvim Station.
Boston Edison also performed a major rewrite (revision) of PNPS Procedure
1.5.3 "Maintenance Request" (MR) to incorporate stronger administrative
controls to identify problems, initiate, plan, track and accomplish station
maintenance with precise supervisory control on both safety-related and
nonsafety-related components, equipment, or structures. A new procedure, PNPS
Procedure 1.5.3.1 "Maintenance Work Plan" (MHP), was developed to be utilized
in conjunction with the Maintenance Request as an administrative tool to
provide a Hork Plan which further defines (details) the work to be performed
including special tools, equipment, procedures, instructions, technical
documentation, expected exposure levels (if applicable) and to provide
feedback when work is completed.
Revisions to MHPs will not change the intent
of the work scope originally approved.
Revisions to the Work Plan will be
reviewed and approved in the same manner as the original document.
The Work
Plan and the parent MR are the controlling documents for installation of a
modification or performance of a maintenance work activity.
The Work Plan
specifies the requirements for examination, and testing, and includes the
applicable instructions, procedures and drawings.
It also specifies
hold / witness points and provides for controlling the work in the event of a
nonconformance,
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The highlights of these major revisions to PNPS Maintenance procedures are:
(1) the work documents are incorporated into a single work package for each
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work activity, (2) the process of the Maintenance Work Package provides
increased control in that the engineer who develops the package maintains
control during the process, (3) Management level review and approval of
revisions, including Quality Control and Operations, are part of the process,
and (4) the final package, along with copies of the required documentation is
returned to the engineer for review, closure, and processing to Document
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Control.
These procedure revisions have been completed, reviewed, approved
and implemented.
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ATTACHMENT 'A'
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Insoection Recort 88-17 Rt1RADit
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Boston Edison has conducted a series of formal training sessions for the
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Maintenance Managers, Supervisors, Maintenance Craft and selected personnel
from other sections that are directly or indirectly involved in the
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processing, review, or examination of the new MR/MHP process.
This training
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was completed on June 17, 1988, with program implen,entation on June 20, 1980.
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To reduce the impact on production, and provide a smoother transition,
management oversight of the new MR process is being increased during the
implementatlan phase.
In addition, the Quality Assurance Surveillance
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Division will be conducting surveillance on the revised Maintenance Program to
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monitor implementation and performance.
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This response focuses primarily on the corrective actions taken to resolve the
concerns described in Section 1.2 of the Team Report, Other corrective
actions and program improvements have also been identified and are being
addressed by Boston Edison Management. Although some items are not designated
as RESTART actions, these items are incorporated into long term programs such
as the "Material Condition Improvement Action Plan" (MCIAP).
Boston Edison is
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continuing these actions / improvements with the goal of achieving and
sustaining the highest standards of maintenance performance.
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BG">'lDN EDISON
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Pd sn h'uc! car Power station
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Rocky H41 Mo4d
f rymouth, Massachusetts 02360
Ralph G. Die
sener voce eres
July 7,1988
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U.S.1;uclear Pegulatory Commission
BECo Ltr. #88-103
Attn:
Document Control Desk
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Hashington. D.C. 20555
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Docket No. 50-293
1.icense_No_DPR-35
Subject:
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Soool.emer,tal Rescoqse to NRC Insoection
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Bg;m 1 No. 50-293/88-11
Dear Sir:
Maintenante staffing and performance and suppleThe
with respect to
NRC Inspection 88-17 dated 6/25/88
The information is submitted inments our initial res
a telephone conversation on July 1, 1988.accordance with an
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r. Highfill during
Please do not hesitate to conta
regarding the attached response.ct me if there are questions or comments
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PJH/dmc
Attachmept
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cc: Mr. William Russell
Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
475 Allendale Rd.
King of Frussia, PA 19406
Sr. Resident Inspector - Pilgrim Station
Standard BECO Distribution
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Boston Edison Company
BECo Ltr:
88-103
Pilgrim Nuclear Power Station
Docket No. 50-293
License No. DPR-35
hpplemental Resoonse to NRC Inspection. Report No. 50-293/88-17
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The Haintenance organization, including supervisory and planning positions, is
fully staffed with a combination of Boston Edison and contractor personnel.
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An aggressive process is in place to hire permanent personnel for those
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positions currently fil'.ed by contractors. Current projections show permanent
positions will be filled with Boston Edison personnel by August 31, 1988. Our
plan is to maintain the Maintenance Organization fully staffea (i 5 positions)
utilizing contractors when necessary.
The existing Haintenance staff (both Boston Edison and contractors) is trained
on the recent changes that were made to enhance the work control process.
New
personnel will be trained as appropriate on the process which is discussed in
our initial response to Inspection 88-17.
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To increase the attrartiveness of jobs in Haintenance, specific actions have
been taken:
Physical working conditions have been improved as a result of the plant
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decontamination program.
Fewer jobs require the use of cumbersome
protective clothing to perform.
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Administrative workload on Haintenance supervisors has been reduced by
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addition of the System Engineering Division and implementation of the
Haintenance Planning Division.
Maintenance work controls have been
upgraded providing more specific guidance to the individuals performing
maintenance activities.
Haintenance staff overtime has been reduced.
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The supervisor to craft ratio has been improved,
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1.ong term action to upgrade supervisory training has been initiated.
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Specific perfor: nance goals in the Haintenance area have been established for
restart and operation. The goals are based on industry guidance and are
published / posted routinely to keep personnel informed of progress towards the
goals.
P_er foLmanct
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In response to the results of Inspection 88-17, several actions have been
taken to ensure adequacy of previously performed maintenance activities.
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JUL 08 '88 16 01 PILGRIM NRC RESIDENT
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61IACHMENTJ
(Cont'd)
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EUDA).gmental Resom.e to NRC_Insoection Reonrt No. 50
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3oston Edison Company has reviewed the concerns identified by the
Team regarding the sample of Haintenance Requests (MR) revie
spection
during the Haintenance Inspection.
e team
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These concerns are currently being
activities by reviewing and compiling availabl
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was performed by these hrs.
Where documentation was not available, walkdowns
were performed to ensure adequacy.
To date no rework has been identified.
The documentation for one post work test could not be located
assessment of these concerns is expected to b
To address
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The
Quality Control Divisions oversight of work on sa
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The
qualified maintenance staff at Pilgrim Station.In summary, a
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program improvements are adequate. assessment indicate that ma
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Our conclusion is based on the assessmen
of historical maintenance records and walkdowns performed to date
resulted in no rework, coupled with the Quality Assurance Depa
of previous activities.
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